Your complete diversionprevention assessment includes:

Thorough report on the risks and gaps in your facility’s handling of controlled substances

Recommendations/options for process improvement

Implementation plan where we work with your team to make improvements

It can happen to you.Whether it’s a trusted employee, long-time client or even a relative, veterinary practices are at risk for drug diversion.

It’s imperative that you be prepared. Now is the time to investigate, identify, correct and strengthen your veterinary practice against the most common vulnerabilities you face today. Keeping up with changing standards, best practices, new requirements and growing threats are the most effective ways to protect your business. But failing to adapt to these new realities may not only cost you financially, it can also cause irreparable harm to your personal and professional reputation.

Today’s DEA rules and regulations are so complex, business owners and practitioners struggle to understand what they should be doing.

Plus, the opioid crisis has resulted in more federal and state resources being put toward preventing drug diversion. And, the pressure is on investigators to step up controlled-substance compliance programs and conduct even tougher oversight.

Hefty civil fines are being levied against non-compliant individuals and businesses across the healthcare industry, including veterinary practices. The current federal fine per infraction is $15,040. But, it’s not uncommon for fines to exceed $1 million, not including the risk of having your DEA registration revoked and the negative fallout from publicity.

Source: DEA (2003-09). With increased inspections and a 45% increase in the average fine, it is estimated that these numbers may actually be 25% or more higher in recent years.

Vets treating large animals or working at horse tracks can be prime targets for individuals seeking to abuse anabolic steroids.

Source: Pharmacy Times, 7/31/17

Most common violations cited by the DEA:

Poor Veterinary Record-Keeping

Failure to Prevent Drug Diversion

Lack of Physical Security

DEA Registration Issues

In 2017, drug overdoses killed more Americans than the Vietnam and Iraq wars combined.

Driven by the current opioid crisis, DEA and state agencies have dramatically stepped up regulatory inspections on healthcare providers who use, dispense or prescribe controlled substances, including veterinarians.

We engaged TITAN for a gap analysis, which was a very easy process. They identified our strengths and weaknesses and we decided to go ahead with a full audit. Now if the DEA comes knocking, we’ll be 100% compliant.”

Sabrena L. Hartley

CVT President/ Owner, Rossmoyne Animal Emergency Trauma Center

In one case involving a veterinarian, a dog owner tried to obtain hydrocodone to maintain his addiction. He even trained his dog to cough on cue.

Source: Pharmacy Times, 7/31/17

America’s drug crisis could be a crisis for your business too.

It’s not a matter of if drug diversion will take place, but a matter of when.

If you’ve been worrying about your own level of compliance risk, it may already be too late. Let us help you TITAN-up your DEA compliance.

Having the right plan and the right partner can mean the difference between quiet resolution and public indictment. To assess the risk in your business, take the free TITAN Risk Assessment Quiz.

The Titan Group DEA was founded by a retired DEA Supervisory Special Agent and is a full-service regulatory compliance, drug security and anti-diversion solutions provider.

With 150+ collective years of law enforcement, security and private-industry experience, the TITAN team of experts helps veterinary practices stay compliant, avoid penalties and deter criminal activities.

DEA Form 106

Theft or Loss of Controlled Substances.

Submitted/utilized only by a person registered with the DEA to handle controlled substances.

Federal regulations require that registrants notify the DEA Field Division Office in their area, in writing, of the theft or significant loss of any controlled substance within one business day of discovery of such loss or theft.

The registrant shall also complete and submit to the Field Division Office in their area, DEA Form 106, “Report of Theft or Loss of Controlled Substances” regarding the theft or loss. (21 C.F.R. § 1301.76(b))

DEA controlled substance registrants are strongly encouraged to complete and submit the DEA Form 106 online. In addition to being more convenient, completing the form online results in fewer errors. A link to the online DEA Form 106 is provided below.DEA Form 106 Online

If a registrant does not have internet access, a paper copy of the DEA-106 form can be requested by writing to: